UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

CHURCH OF SCIENTOLOGY
INTERNATIONAL, a California
non-profit religious
organization,

Plaintiff,

vs .

STEVEN FISHMAN AND UWE GEERTZ,

Defendants.

Case No. CV 91 6426 HLH (Tx)

DECLARATION OF ROBERT VAUGHN
YOUNG IN SUPPORT OF COST BILL
FOR DR. GEERTZ'S MOTION FOR
AWARD OF COSTS, EXPENSES,
ATTORNEY'S FEES AND SANCTIONS

Date: APRIL 4, 1994
Time: 10:00 a.m.
Courtroom: 7

[Filed and served
concurrently with Dr
Geertz's Bill of Costs.]

DECLARATION OF ROBERT VAUGHN YOUNG

I, Robert Vaughn Young, declare that I am over 18 years of age
and am a resident of Newport Beach, California.

INTRODUCTION

I have been retained as an expert consultant and expert witness
by Dr. Uwe Geertz's counsel in the case captioned Church of
Scientology International v. Steven Fishman and Uwe Geertz.
*CV-6426-HLH (Tx) currently pending in the United States District
Court, Central District of California. The statements herein are of
my own personal knowledge or reasonably based upon information and
belief, and if called upon as a witness, I can testify competently
thereto.

This declaration is submitted in support of Defendant Dr.
Geertz's motion for costs, fees, expenses and sanctions following
the dismissal of this action with prejudice by the court on February
22, 1994.

My credentials as an expert on Scientology includes over 20 years
as a staff member in the organization. In those 20 years, I have held
nearly every type of position at every echelon. I have worked at the
local, the regional, the national and the international levels. I
have been a Scientology representative and spokesman before
governmental bodies, the media andthe courts. I have trained others
on how to handle the media and governmental agencies. I have been the
most senior public relations executive for Scientology world wide. I
worked for years at the echelon that handles critics, "enemies," the
media, judges, the courts and the government. I have been privy to
documents and tactics of the most secret nature, including
illegalities committed by Scientology executives and the means of
cover-up. I have been called on many occasions to personally handle
"hot" situations of the most sensitive nature ranging from the
mysterious death of the son of Scientology Founder Ron Hubbard
("Hubbard") to the death of Hubbard himself. I have been privy to
financial schemes and scams involving tens of millions of dollars. I
also know how Scientology manipulates the law to avoid any revelation
of the truth.

SCIENTOLOGY ADVOCATES USING THE COURTS NOT TO SEEK JUSTICE BUT TO
HARASS AND RUIN PEOPLE

Plaintiff Church of Scientology International's ("CSI") request
that this case be dismissed is in keeping with one of their most
senior scriptures," to use to courts to harass and ruin people rather
than win. It has been a primary tactic since Hubbard gave the edict
in 1955 when he wrote the purpose of bringing a lawsuit:

"The purpose of the suit is to harass and discourage rather than
to win. The law can be used very easily to harass, and enough
harassment on somebody who is simply on the thin edge anyway, well
knowing that he is not authorized, will generally be sufficient to
cause his professional decease. If possible, of course ruin him
utterly." (From Hubbard's 1955 "The Scientologist: A Manual of
Dissemination of Material." Emphasis added. Attached as Exhibit A)
The basic reason that Scientology does not use the courts for justice
is because Hubbard believed the Scientology justice system he invented
was vastly superior and that his system should become the planetary
standard.

DR. GEERTZ IS THE TARGET OF SCIENTOLOGY'S VOW TO DESTROY "THE
PSYCHS"

The key to understanding the mystery of the current lawsuit and
its tortuous route will be found in the above Hubbard directive plus
one further element: Defendant Dr. Uwe Geertz is a psychologist.
Scientology has vowed to destroy and take over the field of mental
health. Thus Dr. Geertz is the target of Scientology's equivalent of
"The Final Solution," where a profession has become a universal
scapegoat.

PSYCHS ARE SCIENTOLOGY'S SCAPEGOATS FOR EVERYTHING INCLUDING SEX

It is drilled into every Scientologist's head that all troubles
and problems - Hubbard's, Scientology's, America's, the world, this
corner of the galaxy and literally the entire universe - are due to
psychiatrists and psychologists, known collectively as "the psychs."
In fact, Hubbard said the ONLY cause of crime is the "psychs." He even
goes so far as to say "there are no laws at all which protect them."
from being attacked. (See Hubbard's "The Cause of Crime," Attached
as Exhibit B. See also declaration of Stacy Young also filed this
date.)

The "psychs" are Hubbard's scapegoat for all historical ills
going back not merely scores of years but hundreds, thousands and even
millions of years. In Hubbard's paranoid view, everything from rock
and roll to the Third Reich and even sex itself were vile inventions
of 'psychs'. (See "Pain and Sex." Attached as Exhibit C.) As
incredible as that may seem, Hubbard actually believed that sex was
literally invented by "psychs" millions of years ago. While he
doesn't come out and say it, the implications are clear: all sex -
even the attraction between couples - is bad.

The intensity of Hubbard's anti-sex (and especially
anti-female) attitude is not known to many Scientologists. Starting in
1981, I had full access to Hubbard's most private papers, diaries and
letters. I continued to have unlimited access to it for years as part
of the work to write a biography of Hubbard and was able to read
letters to and from his parents, wivesm mistresses, friends and
business associates. There were hundreds of thousands of pages of
material - much of it originals or carbon copies in his own
handwriting - that detailed his views about his life, his wives, his
family and sex. Much of this was written in the 1930s and 1940s but
extended into the 1970s. Some of these papers were diatribes against
females and were covered with red-ink drawings of genitalia around the
margins of the pages. He also graphically described what he wanted to
do to women, including hurting and raping them. Suffice it to say
that it was x-rated and sadistic. This was my initiation into the
dark side of Hubbard's views. (These papers were subsequently locked
away so no Scientologist will even know they exist, let alone allow
anyone to see them.)

Hubbard's anti-female attitude appeared first, in private
writings in the 1930s and 1940s. His views of "the psychs" developed
after the publication of his first Scientology books in 1950 when he
was courting "the psychs" for approval of his system. When he was
rebuked andcriticized, he became incensed and began to blame them for
his troubles with the press and his customers.

Thus Dr. Geertz is viewed as a part of the international (and
intergalactic) conspiracy that must be annihilated before Hubbard and
Scientology can reign on Earth.

CSI'S CASE IS PART OF THE "FAIR GAME DOCTRINE" AND "PSYCHS" ARE
FAIR GAME

CSI has a Fair Game Doctrine where any "enemy" can be
"destroyed." This doctrine is practiced against apostates, critics,
the press and has even been used against courts. It has been
practiced against Dr. Geertz (starting with this lawsuit that put him
into bankruptcy) and his counsel in this case (ranging from an
investigation that this court ordered stopped to vandalism of Mr.
Graham Berry's property.

I will show how the Fair Game Doctrine started, how it has
continued to this day and how this court has been exposed to these
end- justifies-the-means methods. I will present this using the
writings (now called "scriptures") of Hubbard. These are the
iron-clad policies of Scientology.

"FAIR GAME": THOSE THAT HAVE NO RIGHTS; THEY AND/OR THEIR
PROPERTY CAN BE DESTROYED

The doctrine of Fair Game was codified on March 7, 1965, when
Hubbard issued titled "Suppressive Acts: Suppression of Scientology
and Scientologists: The Fair Game Law" (Attached as Exhibit D) Hubbard
wrote,

By FAIR GAME is meant, without rights for self, possessions or
position, and no Scientologist may be brought before a Committee of
Evidence or punished for any action taken against a Suppressive Person
or Group during the period that person or group is 'fair game'. A
revision of December 23 1965, changed it to read, "By- FAIR GAME is
meant, may not be further protected by the codes and disciplines of
Scientology or the rights of a Scientologist." As to what was a
"suppressive person," Hubbard gave the definition:

A SUPPRESSIVE PERSON or GROUP is one that actively seeks to
suppress or damage Scientology or a Scientologist by Suppressive Acts.

SUPPRESSIVE ACTS are acts calculated to impede or destroy
Scientology or a Scientologist and which are listed at length in this
policy letter. (Caps in original). Some of the suppressive acts
listed included "public disavowal of Scientology; public statements
against Scientology;" asking for a refund of fees paid; and "writing
anti-Scientology letters to the press." Even turning a Scientologist
into the proper authorities can gain one the label of a suppressive.
The issue also prohibits "1st degree murder, arson, disintegration of
persons or belongings not guilty of suppressive acts." (Emphasis
added.) In other words, killing suppressive persons or destroying
their property promotes Scientology and is therefore ethical within
the Scientology belief system.

WHY SCIENTOLOGISTS CANNOT GIVE UNBIASED TESTIMONY

The material just quoted also shows why Scientologists cannot
give unbiased testimony. If the testimony is viewed as critical of
Scientology or a Scientology executive, it would be a "public
disavowal" and a "public statement against Scientology" and would be a
suppressive act. The person could then be kicked out of Scientology
and be made Fair Game and sued. Since Scientologists don't want this
to happen to them, they will not make any critical remarks or remarks
that may be deemed critical. This is why Scientology officials have
insisted that only active Scientologists can be experts" - because
they will be biased to Scientology rather than responding fully and
honestly to the Court.

AN EXAMPLE OF HUBBARD IMPLEMENTING FAIR GAME

Scientologists like to find instances where Hubbard applied a
doctrine so they can imitate it. Hubbard gave an example of how Fair
Game should be applied shortly after he created the doctrine. Hubbard
gave specific orders on how to apply the Fair Game doctrine in HCO
Executive letter 27 September 1965 or. "Amprinistics " (attached as
Exhibit E) This was what he called a "splinter" group, a group that
was using Scientology "technical" methods without his control.
Hubbard's three-page issue blasts the Amprinistics leaders with a
variety of sexual charges (one of his favorite topics for accusations)
and says what should be done: "They are each fair game, can be sued or
harassed. Hornercan be barred out of any Commonwealth Country or
England as he was the subject of a deportation order from England and
his file has come alive again in the Home Secretary's Office. Harry
Thompson's wives and victims are always looking for him to have him
arrested. Watson is a set-up for arrest as a homosexual. Any meeting
held by them should be torn up. The names of any persons attending
should be collected and they should be labeled SP [suppressive person]
as they have left Scientology. These people are SP because they are
seeking to avoid auditing and retain their withholds. Once labeled,
these persons will not then be covered by amnesty and will never be
admitted to further training and processing. Persons messing
themselves up with Amprinistic [techniques] should be refused any
assistance. If these persons move into your area act through any
agency you can to have them deported or arrested on whatever grounds.
England is currently too hot for them so they may tour about.
Horner's UK deportation order, Thompson's police record and Watson's
homosexuality make them very vulnerable to deportation or arrest.
Hubbard does not stop there. He goes on to issue a five-step
order that includes:

"(2) Harass these persons in any possible way....

"(4) Tear up any meeting held and get the names of those
attending and issue SP orders on them and you'll have lost a lot of
rats.

This order has never been canceled and is still "scripture" as
an example how to attack "enemies." In fact, as an example of how Fair
Game was being implemented against another defendant, attached as
Exhibit F is a declaration from former member David Mayo who describes
how he was held captive for six months and was told he would "never
leave the property alive." (See pages 4-8) He describes the duress and
threats as he became the target of the Fair Game Doctrine (or "Fair
Game Law.")

HOW SCIENTOLOGY USES INVESTIGATION AND THE MEDIA TO ATTACK AND
HARASS CRITICS

In 1966, Hubbard began to codify those sections of Scientology
that would implement Fair Game. For example, on February 17, 1966, he
created the Public Investigation Section with a policy letter of that
name and date. (Attached as Exhibit G) He said it would serve "the
useful functions ofan intelligence and propaganda agency. It finds
the data and sees that it gets action." The statistic of the unit
included "the number of derogatory news stories appearing that week
related to enemies of Scientology."

Hubbard also urged the priority of finding evidence of "murder,
assault, destruction, violence, sex and dishonesty, in that order.
Investigations which can uncover these factors in the activities of
individuals or a group attacking Scientology are valuable in the
degree that they contain a number of these factors." And note that
Hubbard's use of such evidence is not for law enforcement but to the
media. "In that way," he wrote, "we then Get rid of suppressive
groups by investigation and disclosure." (Emphasis added.)

The next day, on February 18, 1966, Hubbard wrote "Attacks on
Scientology" (Attached as Exhibit H) in which he again urged the use
of investigations. Suppressives, he said, have by definition comitted
criminal' acts. "These people who attack have secrets. And hidden
crimes. They are afraid." He thus urged they be investigated as this,
he said, would cause the attacker to withdraw.

A week later, on February 25, 1966, he wrote another "Attacks on
Scientology" policy letter (Attached as Exhibit I) in which he urged,
to "Start feeding lurid, blood sex crime actual evidence on the
attackers to the press.

See also Hubbard's "How To Do a Noisy Investigation" of 5
September 1966 (Attached as Exhibit J). The target is "attackers of
Scientology".

FAIR GAME DOCTRINE SPECIFICALLY INCLUDES THE FILING OF LAW SUITS

On October 18, 1967, he issued "Penalties for Lower Conditions"
(Attached as Exhibit K) whereby Fair Game was automatically issued on
anyone (including staff members) who was an "enemy." Such people were,
he said, "Fair game. They may be deprived of property or injured by
any MEANS by any Scientologist without any discipline of the
Scientologist. May be tricked, sued or lied to or destroyed."
(Emphasis added.)

CANCELLATION OF FAIR GAME ONLY MEANT NOT USING THE WORDS ANY MORE
BECAUSE IT CAUSED "BAD PUBLIC RELATIONS"

In the late 1960s, Hubbard was having growing public relations
problems. One problem was Fair Game. To deal with it, Hubbard wrote
an issue that is often cited by CSI as evidence that Fair Game was
canceled. But a careful reading will show that nothing has changed
but semantics. The issue is "Cancellation of Fair Game" dated 21
October 1968. (Attached as Exhibit L) The entire text of the policy
letter (P/L) is as follows:

"The practice of declaring people FAIR GAME will cease. FAIR
GAME may not appear on any Ethics Order. It causes bad Public
relations. [Emphasis added.] This P/L [policy letter] does not cancel
any policy on the treatment or handling of an SP. [suppressive
person] L. Ron Hubbard Founder

THUS THE SO-CALLED "CANCELLATION" OF FAIR GAME DID NOT CANCEL THE
USE OF FAIR GAME TACTICS.

The original directive that CSI uses to say the Fair Game
Doctrine was canceled expressly establishes that the only change was
to stop using the words "Fair Game.". Hubbard was quite clear that
tactics were not to change. only the use of the words in public. As
further evidence of Fair Game continuing, Hubbard later
wrote"Confidential: Targets, Defense" on February 16, 1969, (Attached
as Exhibit M) in which he listed "vital targets on which we must
invest most of our time..." The first and most important: "T1.
Depopularizing the enemy to a point of total obliteration."

MILITARY TACTICS ARE TO BE USED IN FAIR GAME

On the same day, February 16, 1969, he wrote "Confidential:
Battle Tactics" (Attached as Exhibit N) where he urged the use of
military tactics and strategy in dealing with the "enemy." He wrote,

"A good general expends the maximum of enemy troops and the
minimum of his own. He makes the war costly to the enemy, not to
himself. One cuts off enemy communications, funds, connections. He
deprives the enemy of political advantages, connections and power. He
takes over enemy territory. He raids and harasses. All on a thought
plane--press, public opinion, governments, etc. (Emphasis added.)

FAIR GAME TACTICS EXPLAIN THIS LAWSUIT

When the Fair Game Doctrine and Scientology's "Final
Solution" attitude towards "psychs" (psychologists and psychiatrists)
are understood, this lawsuit can be understood. It will also be seen
that what was at issue was not the deposition of the "celebrities" but
those of the executives who were in non-compliance with this Court's
Order. The reason was simple: they are the ones who directed this
entire campaign.

HOW SCIENTOLOGY ATTORNEYS ARE USED TO CLAIM "ATTORNEY WORK
PRODUCT"

Surveillance is one of the standard tactics used by Scientology
and CSI. It is often done by staff from the Office of Special Affairs
("OSA"). Tougher or more important assignments are given to private
investigators who are paid by attorneys so the investigation can be
called "attorney work product." This practice was because the 1977 FBI
raid shattered Scientology's intelligence network.

The court should note that it has been told that such practices
were done by a previous Scientology administration that has been
eradicated. This is not true. I am attaching the billings of a
private investigator who was doing surveillance on author Omar
Garrison and apostate Gerry Armstrong in 1982. (Attached as Exhibit
O) These were billed to attorney John Peterson. ("Peterson") However
this investigation was being directed by David Miscavige ("Miscavige")
who at the time (mid-1982) was my senior in an organization called
Author Services, Inc. ("ASI") ASI was a for-profit group that was
purportedly a literary agency handling Hubbard's books. We did handle
Hubbard's works but our real function was to serve as Hubbard's
personal arm into the non-profit Church of Scientology. This
investigation by Tin Goose of Omar Garrison and Gerry Armstrong was
paid for by Church of Scientology funds on Miscavige's orders while
Tin Goose reported directly to Miscavige. Peterson was merely the
"cutout," to make it appear that it was attorney work product and to
keep it away from ASI.

HOW MISCAVIGE USED A "DOUBLE-BLIND" TO GO AFTER AN ATTORNEY

In 1982 a "double-blind" system was initiated by Miscavige when
he was directing the campaign against Boston attorney Michael Flynn.
("Flynn") Flynn had been representing plaintiffs in suit against
Scientology and Hubbard, and Miscavige was demanding that Flynn be
destroyed. (This is the Fair Game Doctrine although the words were
never used, per Hubbard's orders.) Peterson was told to hire another
attorney who had no connection or any knowledge of Scientology. That
fresh attorney was to hire the private investigators to undertake
certain harassing actions on Flynn. Thepurpose of the double-blind
was if the investigator was caught and traced to an attorney, it would
not be one hired by a Scientology group and any illegalities could be
protected twice as attorney work product.

With the formation of the firm of Bowles and Moxon (attorneys for
plaintiff in this case), investigations were moved to them rather than
attorneys like Peterson because Bowles & Moxon are Scientologists and
can be manipulated and threatened. Peterson was not a Scientologist
and could not be so controlled.

EXPERTS AND COUNSEL ON THIS CASE WERE KEPT UNDER SURVEILLANCE

The court was advised of the investigation of counsel Graham
Berry and ordered that it be stopped. (It was not because CSI cannot
stop. Such investigations are required by Hubbard's "scriptures.") A
similar investigation and surveillance was done of other experts on
this case including myself and my wife. This went on for months. We
have been tailed on the freeways, in shopping malls and even while a
hundred miles from home on a day off. (In one instance, a tail I
accosted confessed that he was tailing me and that he was Scientology
staff.) Our trash has also been pilfered and former employers and
associates interviewed. All of this is in keeping with the Fair Game
Doctrine, hoping that they will find something to intimidate the
person with. (If that doesn't happen, then something is concocted.
They are now doing that with me, asserting that I assaulted a
Scientologist in the city of Hemet. Their insistence that I be
charged is being led - appropriately enough - by one of their key
public relations people, Ken Hoden, who gets his orders from David
Miscavige ("Miscavige") who is the head of the Scientology empire. At
this writing, nothing has come of their baseless allegations.)

EXAMPLE OF TARGETING A PERSON IN LITIGATION WITH SCIENTOLOGY

Attached as Exhibit P is a Scientology program ("Julie's
Background") designed to deal with a court problem in 1979. Julie
Christofferson. She had sued the church and this program was written
to document that the people involved in the Christofferson case are
criminals with criminal backgrounds and criminal records and that they
engage in a criminal conspiracy to defraud the organization under the
guise of "home and mother." Julie appears to be pure as the driven
snow, so considerable background data [Scientology's euphemism for
covertly obtained data] on her is needed to give usdirection in
locating the real facts of interest about her.

Those "real facts of interest" are stated in the next paragraph
as to what Scientology wants on the plaintiff. The criminal
background, drug history, record of arrests, former employment,
perversions of Julie, fully known and documented, as needed.

The program then goes on for pages to tell how to do this. There
is nothing to indicate there is anything to find, merely the
Hubbard-driven assumption that anyone who sues Scientology or attacks
Scientology must by definition be a criminal. The program was written
on Hubbard's direction.

CSI'S REFUSAL TO COMPLY IS BECAUSE OF CSI'S COMPLETE DISDAIN FOR
ANY SYSTEM OTHER THAN HUBBARD'S

CSI's general non-compliance with the orders of this Court was
because of the disdain that Hubbard and the current leadership have
for this and any court as well as the law. Time and again Hubbard
wrote how his system of "justice" was superior to any system.
Additionally Hubbard and Scientology were constantly being challenged
by the courts. In Hubbard's view, neither he nor Scientology should
have to answer to anyone.

ACCORDING TO THE SCIENTOLOGY BELIEF SYSTEM. THE COURTS ARE PART
OF A CRIMINAL PLAN DIRECTED BY "THE PSYCHS"

Another reason Hubbard and Scientology hold the courts in such
disdain is Hubbard's view that the purpose of the justice system is to
support psychologists and psychiatrists. This is done by "psychs"
creating criminals who keep the courts alive who feed them back as a
self- perpetuating system, funded entirely by the government. Hubbard
wants to have the criminals fed to Scientology and to replace the
legal system of justice with Hubbard's system, thus collecting the
money that he felt is going to the psychiatrists and psychologists.
(See attached as Exhibit Q "The Criminal Mind and The Psychs,"
attached as Exhibit R "The Cause of Crime," attached as Exhibit S
"Criminals and Psychiatry," and attached as Exhibit C "Pain and Sex.")

THE ORDERED DEPOSITIONS SHOULD HAVE PROCEEDED

The Court ordered David Miscavige, Norman Starkey, Mark Yager,
Ray Mitoff, Lyman Spurlock, Marty Rathbun, Greg Wilhere and
Jonathan Epstein to deposition. Most have, in turn, filed declarations
to explain why they know nothing that is germane to this case. To the
contrary, these are the executives who know more about this case than
any other people.

Despite Miscavige's protests, he runs all of Scientology,
regardless of corporate lines. In Scientology, there is only
Scientology. Corporate lines are set up as ways to deflect the
courts, the IRS and the authorities. When it comes to everyday work,
Miscavige is appraised of every part of Scientology, from the church
to the secular. He also issues orders to all sectors and approves all
major transactions. His role is as the head of Scientology is well
known within Scientology. It is only when it comes to matters such as
this suit that he and his lieutenants must suddenly conjure up the
corporate lines and claim ignorance.

MISCAVIGE KNEW OF FISHMAN AND CROSSED CORPORATE LINES TO DEAL
WITH FISHMAN'S MONEY

Additionally, Miscavige knows about Defendant Steve Fishman
("Fishman") and the amounts of money that Fishman contributed to
Scientology. Miscavige had people removed from their positions
because of the Fishman's money and now Miscavige claims he knows
nothing. But Miscavige knew of the massive amounts of money the
Fishman had contributed. Miscavige gave a briefing at Golden Era
Studios near Hemet, California, in 1987 to hundreds of staff (that
included staff from non-CSI corporations) about Fishman's contribution
of about $80,000 for a library of "leather-bound" tapes. In that
briefing, Miscavige screamed and cursed at the head of Golden Era
Studios (Wendall Reynolds) because there were no such tapes to be
sold. Miscavige (who is Chairman of the Board of the Religious
Technology Center, a non-CSI entity) removed Reynolds from his
position on the spot and assigned Reynolds to the gulag known as the
Rehabilitation Project Force where he worked at hard labor for over
two years. (I was sentenced to the same gulag for 14 months.
Reynolds was there when I arrived.) Thus Miscavige not only knows of
Fishman but has admitted it to hundreds of others. His claim he knows
nothing is false testimony, as many can testify.

The others (Starkey, Yager, Mitoff et al) are Miscavige's
immediate lieutenants who carry out his orders into their various
sectors. They too know about the lack of corporate integrity and any
role that Fishman played in Scientology. They also know about the
various Hubbard directives I have quoted from.

FISHMAN WAS BEING URGED TO INVEST IN "SPECIAL PROPERTIES," WHICH
IS NOTHING BUT A FINANCIAL SCAM

The idea of "leather-bound tapes" is part of a line of "special
properties" that was created by Miscavige in 1982 when he was Chairman
of the Board at Author Services, Inc. ("ASI") I joined ASI in
February, 1982, and left it in 1989. One of ASI's functions was to
make millions of dollars for Hubbard. One way was by investments of
Hubbard's fortune, which Miscavige directed, even though Miscavige had
no investment background. Miscavige poured millions of dollars into
oil speculation and lost it without telling Hubbard. (At one point
the estimate was that Miscavige had lost about $50 million of
Hubbard's.) "Special Properties" was Miscavige's idea on how to recoup
the millions before Hubbard (and the IRS) found out. The idea was to
create "leather-bound special editions" and other items that could be
sold at outrageous prices as an "investment". Those who bought books
at thousands or even tens of thousands of dollars were then told a few
months later how their "investment" had increased. Meanwhile, on the
open market, the books were worth perhaps a hundred dollars, which was
why Miscavige prohibited the open sale of these "Special Properties."
(ASI now denies that there ever was a line of properties for
investment.") This was how Fishman came to spend an astounding $80,000
for a set of "leather-bound" tapes, which didn't even exist, and why
Miscavige knew.

CSI HAS MISREPRESENTED ITS ROLE IN RELATION TO THE "CELEBRITIES"

CSI's claim that it didn't want to put its "celebrities" through
a hardship is patently ridiculous. In my 20+ years in Scientology
(which included working with many of them), I never once heard
anything like this. To the contrary, it was just the reverse:
"celebrities" would complain how they were being used, how they were
being ordered to promote Scientology and being made to make media
appearances when there was a legal problem or a problem in the media.
The fact that these "celebrities" did not appear for their ordered
depositions shows the control that CSI has over them. Now CSI turns
it upside down again, claiming their welfare is why they want to drop
a three-year old suit that has cost millions of dollars.

THE DEPOSITIONS OF THE "CELEBRITIES" DID NOT INVOLVE CONFIDENTIAL
MATERIAL

CSI has made it a point that several "celebrities" will be
exposed to "confidential" material if forced into deposition. I know
what material CSI was referring to and those materials had nothing to
do with the ordered depositions. The "confidential" material is what
is called "upper level" material in Scientology. This material is
reserved for certain steps in Scientology "counseling," and had
nothing to do with the ordered depositions of "celebrities," none of
whom are even familiar with them.

At no time has attorneys for Dr. Geertz asked me for any
assistance in handling this material, as to what it might mean, how
they might ask questions about it, how they might use it or how the
material might be presented to a person in any deposition, let alone
indicate in any way that they intend to use those materials with those
"celebrities." Nor are attorneys for Dr. Geertz capable of doing this
without expert help for the material in question is highly arcane,
complex and bizarre and will make absolutely no sense to anyone
outside of Scientology. Thus the idea that attorneys for Defendants
will somehow expose these "celebrities" to this "upper level" material
is merely a sham and an excuse. What was feared was that the other
depositions would occur, namely that of Miscavige, Starkey, Yager,
etc.

CSI's attempt to use their own refusal to comply with the court
as the reason for dismissal is a classical Scientology
through-the-looking-glass strategy.

DENIAL OF LEGAL LIABILITY WAS A TACTIC TAKEN ORIGINAL WITH
HUBBARD

It was a long a well-known fact to Scientology executives that
Hubbard ran Scientology, even though he had made public claims he was
not. That was why there were programs to make it appear that Hubbard
had no legal connection to the church. That tactic is what is now
being used for Miscavige who has taken over Hubbard's position at the
top of Scientology, even though Miscavige runs it just as Hubbard did.
(See Exhibit T for "Operation Bulldozer Leak", a program designed to
create that impression.)

CSI HAS NOT REFUTED YOUNG'S STANDING AS AN EXPERT

In the declarations filed to claim discovery is complete, CSI has
tried to refute my standing as an expert, even going to far as to
twist the facts. For example, Miscavige tries to refute my claim that
I arrived on the scene of Hubbard's before the authorities by saying
that I arrived with some gardeners and cooks. This is not only not
true but ridiculous since I arrived in the same entourage as Miscavige
himself, two private investigators and attorney Earl Cooley who
handled the disposition of Hubbard's body. Miscavige knows that I was
a top Hubbard aide who was privy to considerable material and so do
many others. He (Miscavige) can no more tell the truth about my role
than he can about his, that he runs all of Scientology. I stand by my
declarations and the documents supplied with them and am confident
that the Court can winnow the wheat from the chaff.

HUBBARD'S DEATH CREATED A POWER STRUGGLE THAT MISCAVIGE WON

Hubbard died in hiding in January, 1986. He had been in hiding
for several years. Even though we were in weekly written
communication with him at Author Services, Inc., it was our task to
pretend we were not, to keep the authorities from knowing how to reach
him. During this time, Hubbard's closest confidant was Pat Broeker
who was living with him as his aide. When Hubbard died, a power
struggle erupted between Broeker and Miscavige as to who would run
Scientology. Miscavige won. Those on Broeker's side were purged.
That included me. I was sent to a desert gulag for 14 months.
Broeker's wife Annie gave in and arrived while I was there. She later
escaped once and was captured and returned and kept under 24- hour
guard. Pat disappeared and no one has heard of him since. It is not
known if he is alive.

HUBBARD'S AND OTHER MYSTERIOUS DEATHS IN SCIENTOLOGY

When it comes to the issue of deaths in Scientology, there are
some important ones to use as a measure, starting with that of its
founder, Hubbard, who died in January, 1986. I arrived at his secret
ranch near San Luis Obispo, California, within hours of his death,
well before the authorities. I went with Miscavige, attorney Earl
Cooley, two private investigators and a few other key, selected staff.
It was our collective task to take command of the situation. The
greatest fear was that there would be a panic in the Church of
Scientology if the circumstances of Hubbard's death were known. For
example, while Hubbard's condition deteriorated in the final weeks,
his personal physician (Dr. Gene Denk) was sent to Reno to gamble,
leaving Hubbard with no medical attention. Or that Hubbard's primary
source of Scientology help was a person who had taken LSD over 1000
times. Or that the story that Hubbard decided to "leave the body"
(Scientology's way of saying "died") was dreamt up at the next morning
to calm Scientologists. Or that the body was quickly disposed of to
avoid any autopsy that would reveal "medicines" that he had been
taking. Thus the actual truth of Hubbard's death has yet to be told.

Hubbard's son Quentin also died under mysterious circumstances in
1976. He had disappeared from his home in Clearwater, Florida, and
was found unconscious in a car next to the Las Vegas airport.
(Coroner's report is attached as Exhibit U. He died unidentified, as
a "John Doe.") The engine of the car was on and a hose ran from the
exhaust pipe (although it appeared to have fallen off when the
authorities arrived) to the window, making it appear to be a suicide.
But, like his father's death, there were a number of nagging
questions. For example, Quentin was found unkempt with a beard
stubble, a state that no one who knew Quentin could accept. (He was
ultra-meticulous in his appearance.) Or that the license plate of the
car was missing and found under a rock some distance away. Or that
his wallet was gone, making identification impossible. Or that a
near-empty bottle of liquor was found, as if he had been drinking,
when Quentin did not. Or that there were needle marks on his arms,
when he did not use drugs.

Another mysterious but key death was that of Flo Barnett,
Miscavige's mother-in-law. She died in 1985 of three shots to the
chest and one to the temple from a semi-automatic rifle. Two suicide
notes were found. Although she was only 5'3" tall (and weighed only
114 pounds), the examiner determined she shot herself three times in
the chest (with a rifle) before shooting herself through the head.
(See coroner's report attached as Exhibit V.) What the authorities
didn't know was that she had left Scientology and was associating with
apostates, to the anger of her son-in-law Miscavige.

Defendant Uwe Geertz was prepared to present information about
other mysterious deaths, murders and suicides of Scientologists and
former Scientologists.

CSI DID NOT COMPLY WITH DISCOVERY

One unfamiliar with Scientology systems might think there would
be no other information to be provided but as a 20-year veteran and
one intimately familiar with the unchanging system, I can attest there
is considerable information that was not provided although requested
by Dr. Geertz.

CSI has repeatedly protested how many documents and people it
made available to Dr. Geertz. Being intimately familiar with
Scientology files and data-gathering procedures, I can say that CSI
has not turned over large volumes of requested material and personnel
to Dr. Geertz that are germane to this case. For example, there are
extensive files (including computerized) that would enable a person to
determine the effect of adverse press. These are kept and maintained
on weekly basis. I personally know of them for I have worked with and
have seen these files. They have been kept by Scientology for
decades. These were not provided to Dr. Geertz. Nor were other
material that would have been collected on Dr. Geertz. such as
reports from private investigators, credit checks, all standard
actions in Scientology proceedings. Nor has CSI supplied material
regarding their investigation of Fishman's role in Scientology even
though CSI's corporate secretary Lynn Farny said he had seen and
reviewed such material.

Nor has CSI supplied those personnel that would know most about
the truth or falsity of the facts in question in the Time magazine
article. Those people are Miscavige. Yager, Willhere and Mitoff,
Epstein, Spurlock and Starkey would know about Fishman's financial
roles and Scientology financial scams.)

IT IS ROUTINE TO ALTER SCIENTOLOGY RECORDS AND FILES TO AVOID THE
AUTHORITIES

As early as 1971, I was introduced to the practice of altering
Scientology records and files to thwart the authorities. This
occurred when I worked as the Temporary Assistant Guardian in San
Francisco. Under me was the Intelligence Bureau which was where
Scientology was running its spies and agents. One day I received an
order from the Guardian's Office United States (in Los Angeles) and
was told to do a "clean-up" on any reference to Marsha Williams
because she was going to become staff of the Intelligence Bureau in
Los Angeles and possibly become an agent. What a "clean-up" meant was
that I was to find and remove any reference to her anywhere in the San
Francisco organization, where she had served, so there would be no
record of her in the organization. This was to thwart any
investigation of her or any trace on her by any authorities. I
removed her name from various records and files and sent the material
to Los Angeles. I later saw her in Los Angeles, as Intelligence
staff, when I joined the US Guardian's Office.

After the Federal Bureau of Investigation ("FBI") raided three
Church of Scientology locations in 1977 to obtain documentation
regarding violations of the law, I worked with scores of other people
to quickly destroy any further evidence to keep it from falling into
the hands of the authorities. We were all verbally briefed how we had
to go through files and look for (1) any documents showing illegal
activity and (2) any documents to show that Hubbard was running
Scientology (which he was but we were trying to tell the authorities
that he wasn't) and to destroy these documents. In this campaign, the
amount of documents that were destroyed were in cardboard boxes
stacked down halls. I do not know the page count but the stack was
about four feet wide, four feet high and about 60 feet long. And this
was from the location with the least amount of files. And there was
no doubt that we were doing this to destroy incriminating evidence.
In fact, several of us questioned this and were told to shut up and
keep shredding paper.

Circa 1983 when I worked at Hubbard's "literary agency" Author
Services, Inc., we were told there was a threat of an IRS raid on us
and we had to move documents. These went to another floor in the
building where we kept watch on them. There were about 50 bankers
boxes of files that we were keeping hidden from the authorities who
were also serving subpoenas to get records. Our task was to keep
these other records secret. The files were kept on that other floor
for a couple of months.

This last instance is cited in particular to anticipate the reply
of CSI that the earlier examples were from an earlier regime that has
been overthrown. This is not true. In fact, the 1983 instance at ASI
was conducted by Miscavige who currently runs all of Scientology.

Thus the cleaning up of files to remove embarrassing or
incriminating material was routine and the non-appearance of Fishman's
name in certain groups is not indicative that he was not there.

CONTRARY TO THEIR DECLARATIONS, CSI IS STILL USING THE ORIGINAL
GUARDIAN OFFICE STAFF

On a number of occasions, CSI has tried to disassociate itself
from the Guardian's Office that was raided by the FBI in 1977 and the
Guardian Office staff that went to jail, including Hubbard's wife,
Mary Sue. It has been CSI's contention that those associated with the
crimes were purged. This is not true.

The precise target of the FBI raid was the Snow White Program in
the Intelligence Bureau of the Guardian's Office. In 1989 the Snow
White Program was still active and one of its key staff was Grace
Marie Haddy. (See "Non-Existence Formula" dated 12/16/89 from Show
White Pgms Chief OSA US attached as Exhibit W) Grace Marie Haddy was a
key executive of the intelligence bureau and was privy to all
communications detailing the illegalities that subsequently sent the
11 executives to jail.

Handling CSI's case before this court is Kendrick Moxon ("Moxon")
who was named as an unindicted co-conspirator when Mary Sue and the
others were indicted. Moxon was head of the Guardian Office Legal
Bureau in Washington, D.C. (See the "Stipulation of Evidence"
attached to the declaration of Vicki Aznaran, also filed 3/9/94 which
includes a description of Moxon's role in obstructing the
investigation of the Department of Justice.)

THIS CASE DOES NOT CONCERN PLAINTIFF CSI

With over 20 years as a staff member in various Scientology
entities, both inside the Church of Scientology and in secular
Scientology groups, I can say with confidence that after reading the
article in Time magazine and the section for which Fishman and Dr.
Geertz are being sued, I did not think of CSI. Although I was well
aware that CSI existed, it would have been one of the last entities
that would have come to mind. The article and the sections in
question are about Scientology as a subject and practice, including
the secular side of Scientology. (The secular side of Scientology is
a multi-million dollar activity that has been kept hidden from the
court. This side promotes that Hubbard's writings - the same ones
used in this case as scriptures" are non-religious and "secular" and
can be used in commercial enterprises to help the business or a
client. This is the Jekyll & Hyde syndrome of Scientology, how they
pretend to be a religion or a business, according to the potential
customer or situation.)

CSI'S CASE DOES NOT HAVE MERIT FOR SEVERAL COGENT REASONS

Besides the fact that the Time article is not about CSI, there
are additional reasons why CSI's case has no merit. Some of these
have already been covered. (1) CSI refused to comply with discovery.
(2) CSI never intended to complete discovery because the suit was
brought solely for malicious reasons (to punish a member of a group
Scientology has promised to destroy, according to the Fair Game
Doctrine.) (3) CSI is not the true plaintiff. Being familiar with the
ecclesiastical and corporate structures of Scientology, I know by
reading the passages at issue that Dr. Geertz was not speaking of
Plaintiff Church of Scientology International ("CSI"). However that
is one of the roles that CSI has, to intervene, because it has the
manpower to wage lawsuits and to carry out the Fair Game Doctrine via
the Office of Special Affairs. (4) There is a likelihood that what
Dr. Geertz said is true, that Fishman was told to "end cycle" and to
kill Dr. Geertz. CSI's refusal to provide information and deponents
has prevented an adequate defense. But based on my 20 years in
Scientology and seeing the level of criminality that was able to
permeate the organization - always kept from the view of all but a
select few - I cannot discount his allegations. (5) Even if
Defendants statements are false, CSI was not hurt. By their own
admission. CSI has no members that can be wronged. Additionally by
Scientology's own writings, no press ever hurts them, especially
anything in Time magazine. To the contrary, they have claimed that
they grow in the face of such adverse publicity. Thus CSI must either
admit that they were not harmed or admit that their Hubbard's claims
of Scientology's infallibility are false.

The simple truth of this case boils down to this: the suit was
brought under the "anti-psych" Fair Came doctrine by an entity without
members and without standing (CSI) because it has an anti-"psych" arm
whose function is to take over the field of mental health and destroy
Hubbard's enemies. I know because I worked at that echelon for nearly
20 years and know it and the tactics intimately.

I declare under penalty of perjury under the laws of the United
States of America and the State of California that the foregoing is
true and correct.